Coming Fall 2025: Codeine Added to M3P Drug List Including Tylenol #3, Tylenol #2, and Cotridin
Coming fall 2025, several codeine-containing products (including Tylenol #3, Tylenol #2, and Cotridin) will be M3P drugs.
8 key points to know regarding the addition of several codeine-containing products to M3P drug list:
Click to jump to each section for more details:
- Codeine becoming an M3P drug must not prevent your patients from accessing pain management when needed.
- ALL physicians can prescribe ALL M3P drugs, if within their scope of practice. No special application or approval is required.
- All M3P prescriptions, including Tylenol #3, can be efficiently written using the free-type field in your EMR. If your practice is paper- based, M3P templates are available in the CPSM Portal (registrant login required).
- The old M3P prescription booklets (triplicate/duplicate pads) are no longer needed (or available).
- All EMR-generated/paper M3P prescriptions can be faxed directly to the patient’s pharmacy of choice or handed to the patient.
- Faxed prescriptions may contain an electronic signature. Prescriptions handed to patients must be signed in ink.
- Pharmacists must ensure M3P prescriptions meet all requirements. Regardless of how your prescriptions are generated, please ensure every codeine M3P prescription contains: a) therapeutic indication, b) total quantity in numbers & words, and c) only one drug per EMR prescription or physical page.
- The Prescribing Practices Program can assist you with streamlining your EMR M3P prescription template for maximum efficiency. Phone 204-774-4344 and ask for the Prescribing Practices Program.
Download a printable poster to remind you of the changes
Codeine becoming an M3P drug must not prevent your patients from accessing pain management when needed.
This change should not restrict patient access to prescribed codeine when clinically appropriate. Prescribing codeine should be approached similarly to other prescription opioids, i.e., conscientious prescribing implementation of universal safety precautions to mitigate the risks. Codeine must be prescribed in keeping with the requirements of the Standard of Practice for Prescribing Opioids.
The rationale for this change includes:
- Codeine contributes to more overdose deaths than any other prescription opioid in Manitoba. Tylenol #3 was not on the M3P drug list for to a variety of historical reasons. This may have created the unintended and erroneous perception that codeine is a safer opioid. This is not the case. All opioids have associated benefits and harms.
- This change is consistent with all other opioids.
- In most provinces, codeine is already treated similarly to M3P medications.
- Several codeine products are already on the M3P drug list, including Codeine Contin, Tylenol #4, Codeine IR, and pure codeine syrup.
Excluding Tylenol #1 (and other exempted codeine products) from the M3P drug list will help maintain patient access to low-dose codeine products that may be prescribed by pharmacist after conducting an assessment.
A public consultation seeking feedback on this change was held from January 13 – February 18, 2025. We thank everyone who submitted their feedback.
ALL physicians can prescribe ALL M3P drugs, if within your scope of practice. No special application or approval is required.
Physicians do not need to apply or be approved to prescribe M3P medications. In short, physicians with a valid CPSM licence (Certificate of Practice), may prescribe M3P drugs if this is within their scope of practice (i.e., they possess adequate knowledge, skills, and clinical judgement to prescribe M3P medications safely), and they have no specific prescribing restrictions from CPSM.
Buprenorphine and methadone are M3P medications that still require prescribing approvals from the Registrar, as per the CPSM Practice Direction for Prescribing Methadone or Buprenorphine/naloxone.
To reduce administrative burden, all M3P prescriptions (including Tylenol #3) can be efficiently written using the free-type field in your EMR. If your practice is paper based, M3P templates are available in your CPSM Portal.
In the CPSM Portal, registrants can access:
- The M3P Prescription Guidance: Requirements & Recommended Templates document that outlines M3P-specific prescribing requirements.
- M3P prescription templates for paper charts to download and customize with your clinic information.
- Examples of how M3P prescriptions can be generated using the free-type field in your EMR.
Templates are not required. However, the paper templates and EMR examples ensure that all required information is present on a prescription. This ultimately minimizes the need for pharmacist-prescriber correspondence to clarify prescriptions and prevents delays in patient care.
The old M3P prescription booklets (triplicate/duplicate pads) are no longer needed or available.
The personalized M3P prescription booklets (also known as triplicate/duplicate pads), which were identified as burdensome, are no longer available to order. Registrants may continue to use any previously obtained personalized M3P prescription pads until they are depleted.
All EMR generated/paper M3P prescriptions can be faxed directly to the patient’s pharmacy of choice or handed to the patient.
M3P prescriptions, electronically generated or handwritten, can be transmitted:
- From the prescriber directly to a specific pharmacy via fax,
- From the prescriber sent via a closed e-prescribing system to a specific pharmacy, or
- Be handed to a patient to take to a pharmacy of their choice.
Patient autonomy, including the right to work with their pharmacy of choice, is paramount. This should be maintained when transmitting prescriptions electronically (via fax or e-prescribing system). Prescribers must NOT influence patients to fill their prescription at a specific pharmacy in any way, directly or indirectly. This is especially important when closed e-prescribing systems are utilized for prescription transmission. Prescriptions cannot be transmitted to the pharmacy affiliated with the same e-prescribing system as the physician’s office for convenience alone. The patient must be asked which pharmacy they prefer, and this choice must be respected.
Faxed prescriptions may contain an electronic signature. Prescriptions handed to patients must be signed in ink.
ALL prescriptions handed to patients must be signed in ink (both M3P and non-M3P prescriptions). For all prescriptions transmitted by fax or by an e-prescribing system, an electronic signature is sufficient.
Pharmacists must ensure M3P prescriptions meet all requirements. Regardless of how your prescriptions are generated, please ensure every codeine M3P prescription contains: a) therapeutic indication, b) total quantity in numbers & words, and c) only one drug per EMR prescription or physical page.
By law, pharmacists are responsible for ensuring prescription appropriateness. Prescribers must be aware of M3P requirements and ensure their prescriptions are correctly written.
Coming fall 2025 (exact date to be determined) new prescriptions for codeine must meet all M3P prescription requirements, including:
- Patient demographics (name, address, PHIN, DOB)
- Name, strength, and dosage form of the drug
- Therapeutic indication (required for all M3P prescriptions)
- Total quantity (in numbers and words) of the drug to be dispensed
- The interval (number of days) at which each quantity (number of tablets) is dispensed (part fill instructions)
- Only one drug per EMR prescription/page
- Directions for use
- Date prescriber
- Prescriber signature
Do not include refills on your codeine prescription. You may include part fills only with the interval between fills clearly specified (i.e., fill 30 tablets every 30 days, total quantity of 90 tablets).
Additionally:
- Verbal prescriptions are not permitted at this time. CPSM is actively pursuing legislative changes that would enable verbal prescribing of M3P medications, under emergency circumstances. We will keep registrants informed of any updates in the future. We appreciate your patience on this matter.
- Physician Assistants and Clinical Assistants will no longer be able to prescribe codeine products to outpatients. (PAs and ClAs previously required a co-signature from their supervising physician to prescribe codeine products to outpatients.)
- M3P prescriptions must be received by the pharmacy within 3 days of issuance.
As an opioid, codeine was always subject to the Standard of Practice for Prescribing Opioids. These prescribing and dispensing requirements remain unchanged.
The Prescribing Practices Program can assist you with streamlining your EMR M3P prescription template for maximum efficiency. Contact us or call (204) 774-4344 and ask for the Prescribing Practices Program.
Please contact us by email or call for Prescribing Practices Program assistance.
Also see CPSM's M3P page and Prescribing Requirements FAQs for more information.